Talking about sustainability

Highlighting important steps to take when communicating sustainability claims.

Image © iStock.com/narvo vexar

Most organisations today will be working to improve the sustainability of their products and operations, and will want to share details of this work with their customers. In fact, larger organisations will be legally obliged to do so, while for smaller organisations these initiatives may offer a crucial point of differentiation and could give a competitive advantage. Sustainability messaging can be communicated to consumers in a variety of different ways, including corporate websites, social media, direct mailers, advertisements, and information on the products themselves or their packaging.

When talking about sustainability, it is vital to communicate in a way that avoids any accusations of ‘greenwashing’ and to ensure compliance with any relevant legislation. Greenwashing has been defined as ‘the use of advertising and public messaging to try to appear to be more environmentally sustainable and green than is really the case’.

What does the legislation say?

In the UK, the Green Claims Code, developed by the Competition and Markets Authority (CMA) came into effect in September 2021 and aims to tackle misleading green claims. The code has six principles:

Be truthful and accurate
Be clear and unambiguous
Do not omit or hide important information
Only make fair and meaningful comparisons
Consider the full life cycle of the product
Be substantiated.

The fashion industry was one of the first sectors to be targeted by the CMA when the code was introduced. This was due to extensive marketing of ‘sustainable’ clothing, accessories and footwear, without any evidence being provided as to what made the item sustainable, or why it might be more ‘sustainable’ than other products being sold by the same company. This eventually led to the release in 2024 by the CMA of a further detailed guidance document for the sector entitled ‘Fashion Retail: Consumer Law When Making Green Claims’.

In the European Union, members had until 27th March 2026 to transpose the ‘Empowering Consumers for the Green Transition Directive’ (ECGT) into national law. This will then apply from 27th September 2026. The directive covers environmental impact claims, durability and repairability claims, as well as assertions about future performance. Claims made must be:

specific and verifiable
supported by evidence or data
based on trusted methods or third-party certification
clear about scope
transparent on future targets.

The directive also targets the proliferation of product sustainability labels and marks that have been seen in recent years. The only labels that will be allowed are those based on certification schemes or established by public authorities. In addition, organisations will no longer be able to make claims about the carbon neutrality of products based solely on carbon offsets that have been made outside of that product’s value chain.

Good and bad practice

In its detailed guidance document from 2026, the CMA provides examples of good and bad practice for each of the six principles of the ‘Green Claims Code’. The details below are provided in relation to making only fair and meaningful comparisons.

Making a claim such as “our sustainable collection is formed using better materials and less damaging production techniques” would not be acceptable as the basis for comparison is not clear. An example of a much better statement would be “our new denim range uses 50 per cent less water than our previous range in the washing, ageing and finishing process”.

Green hushing

The backlash against greenwashing and increasing scrutiny both from legislative bodies and consumers has created the concept of ‘green hushing.’ Green hushing occurs when an organisation decides not to say anything about sustainability because it does not want to be accused of greenwashing, it fears making errors in its communications, or does not want to be challenged about the claims being made.

While this reluctance may be understandable, a lack of communication brings its own challenges. Consumers and supply chain partners expect organisations to be transparent about what they do. Therefore, failing to share progress may mean losing trust or competitive advantage.

Research findings

A recent study undertaken by the ‘Bio-based and Biodegradable Materials Regulatory Network’ (‘BB-REG-NET’) considered in detail effective communication relating to bio-based and biodegradable materials.

The study found that consumers do not understand certifications, standards and legislation that are relevant to these types of materials. The use of terms such as ‘bio-based’, ‘bioplastic’ and ‘compostable’ is very much concentrated in science, finance and health writing. The terms are not used by the wider public, which does not understand them or find them relevant.

While this study had a specific focus, it highlights that the language used by organisations – and specifically in sustainability communications – may not be meaningful or understood by the consumer.

Recommendations

How can organisations communicate with consumers about sustainability when they are faced with all the challenges detailed above?

The legislation is clear – sustainability claims must be substantiated. However, organisations can consider how the message is being delivered to the consumer.

The BB-REG-NET project recommends that on-product communications are based on a ’ten-seconds or less’ rule, and that all communications are tailored towards the likely audience:

who are you talking to?
what do they know?
what might they not understand?
what do they need to know from you in that moment?

The term ‘leather’

A further consideration that will be relevant for most footwear companies is the use of the term ‘leather’. In recent years, a large number of new materials have been launched that are marketed as alternatives to leather, and the term ‘leather’ has been incorporated into the material’s name.

However, the term ‘leather’ is actually protected by law in a number of countries, and must only be used to describe a material made from an animal hide or skin that has been tanned or otherwise preserved. Countries with legislation specifically protecting the term ‘leather’ include Belgium, Italy and Portugal. In many other countries, misuse of the term would be covered by more general consumer protection legislation. Certainly, terms such as ‘synthetic leather’ or ‘vegan leather’ must not be used.

iStock.com/Thomas Faull

In an increasing number of countries, the term ‘leather’ can only be used to describe a material made from an animal hide or skin that has been tanned or otherwise preserved

In conclusion

It is clear that organisations will have to carefully consider any sustainability-related claims that they are making, as well as ensuring that they have evidence to support these claims.

How can we help?

Please email eco@satra.com for further information on verifying and communicating sustainability claims.

Publishing Data

This article was originally published on page 10 of the April 2026 issue of SATRA Bulletin.